UNITED STATES OF AMERICA UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY SOUTHERN DIVISION LONDON V. INDICTMENT NO. ROBERT JASON CHAPMAN, JOHN C. SLUSHER, MARK JUSTICE, GEORGE FERGUSON, RICHARD D. MEADE, aka DICKIE, ROBERT W. HARRIS, aka TRADER BOB, SHON FIELDS, and CHRISTINA BANNIGAN * * * * * THE GRAND JURY CHARGES: COUNT 1 18 U.S.C. 1956(h) On or about a day in January 2000, the exact date unknown, and continuing through on or about February 1, 2008, in Bell, Knox, Boyd, Greenup, and Campbell Counties, in the Eastern District of Kentucky, and elsewhere, ROBERT JASON CHAPMAN, JOHN C. SLUSHER, MARK JUSTICE, GEORGE FERGUSON, RICHARD D. MEADE, aka DICKIE, ROBERT W. HARRIS, aka TRADER BOB, SHON FIELDS, and CHRISTINA BANNIGAN,
did conspire together and with others to knowingly conduct and engage in financial transactions in criminally derived property, affecting interstate and foreign commerce, which, as known by the defendants, involved the proceeds of a specified unlawful activity, that is, interstate shipment of stolen vehicles, knowing the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity, in violation of 18 U.S.C. 1956(a)(1)(B)(i), all in violation of 18 U.S.C. 1956(h). Kentucky, COUNT 2 18 U.S.C. 1956(a)(1)(B)(i) On or about September 8, 2006, in Boyd County, in the Eastern District of ROBERT JASON CHAPMAN, MARK JUSTICE, SHON FIELDS, and CHRISTINA BANNIGAN, aided and abetted by each other, did knowingly and willfully conduct a financial transaction affecting interstate commerce, to wit, the transfer of title to a vehicle, a Harley Davidson motorcycle with a VIN of 1HD1PJE144Y953890, which involved the proceeds of a specified unlawful activity, that is, interstate shipment of stolen vehicles in violation of the laws of the United States, knowing the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity, and that while conducting such transaction knew that the property involved in the financial transaction, that is, the Harley Davidson
motorcycle with a VIN of 1HD1PJE144Y953890 represented the proceeds of unlawful activity, all in violation of 18 U.S.C. 1956(a)(1)(B)(i) and 2. Kentucky, COUNT 3 18 U.S.C. 1956(a)(1)(B)(i) On or about September 20, 2006, in Boyd County, in the Eastern District of GEORGE FERGUSON and RICHARD D. MEADE, aka DICKIE, aided and abetted by each other, did knowingly and willfully conduct a financial transaction affecting interstate commerce, to wit, the transfer of title to a vehicle, a Big Dog motorcycle with a VIN of 5J11RBJ195W000435, which involved the proceeds of a specified unlawful activity, that is, interstate shipment of stolen vehicles in violation of the laws of the United States, knowing the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity, and that while conducting such transaction knew that the property involved in the financial transaction, that is, a Big Dog motorcycle with a VIN of 5J11RBJ195W000435, represented the proceeds of unlawful activity, all in violation of 18 U.S.C. 1956(a)(1)(B)(i) and 2. COUNT 4 18 U.S.C. 1956(a)(1)(B)(i) On or about October 10, 2006, in Bell County, in the Eastern District of Kentucky,
JOHN C. SLUSHER, aided and abetted by another, did knowingly and willfully conduct a financial transaction affecting interstate commerce, to wit, the transfer of title to a vehicle, a Harley Davidson motorcycle with a VIN of 1HD1BRL11VY037198, which involved the proceeds of a specified unlawful activity, that is, interstate shipment of stolen vehicles in violation of the laws of the United States, knowing the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity, and that while conducting such transaction knew that the property involved in the financial transaction, that is, the Harley Davidson motorcycle with a VIN of 1HD1BRL11VY037198, represented the proceeds of unlawful activity, all in violation of 18 U.S.C. 1956(a)(1)(B)(i) and 2. Kentucky, COUNT 5 18 U.S.C. 1956(a)(1)(B)(i) On or about October 19, 2006, in Boyd County, in the Eastern District of MARK JUSTICE, aided and abetted by another, did knowingly and willfully conduct a financial transaction affecting interstate commerce, to wit, the transfer of title to a vehicle, a Harley Davidson motorcycle with a VIN of 1HD1BJL4XVY013364, which involved the proceeds of a specified unlawful activity, that is, interstate shipment of stolen vehicles in violation of the laws of the United States, knowing the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the
proceeds of said specified unlawful activity, and that while conducting such transaction knew that the property involved in the financial transaction, that is, the Harley Davidson motorcycle with a VIN of 1HD1BJL4XVY013364, represented the proceeds of unlawful activity, all in violation of 18 U.S.C. 1956(a)(1)(B)(i) and 2. Kentucky, COUNT 6 18 U.S.C. 1956(a)(1)(B)(i) On or about December 21, 2006, in Boyd County, in the Eastern District of RICHARD D. MEADE, aka DICKIE, aided and abetted by another, did knowingly and willfully conduct a financial transaction affecting interstate commerce, to wit, the transfer of title to a vehicle, a Harley Davidson motorcycle with a VIN of 1HD1BJL44VY057926, which involved the proceeds of a specified unlawful activity, that is, interstate shipment of stolen vehicles in violation of the laws of the United States, knowing the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity, and that while conducting such transaction knew that the property involved in the financial transaction, that is, the Harley Davidson motorcycle with a VIN: 1HD1BJL44VY057926, represented the proceeds of unlawful activity, all in violation of 18 U.S.C. 1956(a)(1)(B)(i) and 2.
COUNT 7 18 U.S.C. 1956(a)(1)(B)(i) On or about March 12, 2007, in Boyd County, in the Eastern District of Kentucky, RICHARD D. MEADE, aka DICKIE, and SHON FIELDS aided and abetted by each other, did knowingly and willfully conduct a financial transaction affecting interstate commerce, to wit, the transfer of title to a vehicle, a Thunder Mountain motorcycle with a VIN of 1T9C1L2686F717095, which involved the proceeds of a specified unlawful activity, that is, interstate shipment of stolen vehicles in violation of the laws of the United States, knowing the transaction was designed in whole and in part to conceal and disguise the nature, location, source, ownership, and control of the proceeds of said specified unlawful activity, and that while conducting such transaction knew that the property involved in the financial transaction, that is, a Thunder Mountain motorcycle with a VIN of 1T9C1L2686F717095, represented the proceeds of unlawful activity, all in violation of 18 U.S.C. 1956(a)(1)(B)(i) and 2. COUNT 8 321 On or about August 29, 2007, in Boyd County, in the Eastern District of Kentucky, and elsewhere, RICHARD D. MEADE, aka DICKIE, aided and abetted by others, did knowingly buy, receive, possess, and obtain control of, with intent to sell and otherwise dispose of, a motor vehicle and motor vehicle parts, to
wit, #62 Harley Davidson purple/gray motorcycle, knowing that the vehicle identification number (VIN) of said vehicle and parts had been unlawfully removed and obliterated, (tampered with and altered), in violation of 18 U.S.C. 2321 and 2. COUNT 9 321 On or about August 29, 2007, in Boyd County, in the Eastern District of Kentucky, and elsewhere, MARK JUSTICE, aided and abetted by others, did knowingly buy, receive, possess, and obtain control of, with intent to sell and otherwise dispose of, a motor vehicle and motor vehicle parts, to wit, #43 Harley Davidson gold motorcycle, knowing that the vehicle identification number (VIN) of said vehicle and parts had been unlawfully removed and obliterated, (tampered with and altered), in violation of 18 U.S.C. 2321 and 2. COUNT 10 321 On or about February 1, 2008, in Bell County, in the Eastern District of Kentucky, and elsewhere, JOHN C. SLUSHER, aided and abetted by others, did knowingly buy, receive, possess, and obtain control of, with intent to sell and otherwise dispose of, a motor vehicle and motor vehicle parts, to wit, #72 Harley Davidson purple motorcycle, knowing that the vehicle identification
number (VIN) of said vehicle and parts had been unlawfully removed and obliterated, (tampered with and altered), in violation of 18 U.S.C. 2321 and 2. COUNT 11 321 On or about February 1, 2008, in Bell County, in the Eastern District of Kentucky, and elsewhere, JOHN C. SLUSHER, aided and abetted by others, did knowingly buy, receive, possess, and obtain control of, with intent to sell and otherwise dispose of, a motor vehicle and motor vehicle parts, to wit, #73 Harley Davidson white motorcycle, knowing that the vehicle identification number (VIN) of said vehicles and parts had been unlawfully removed and obliterated, (tampered with and altered), in violation of 18 U.S.C. 2321 and 2. COUNT 12 321 On or about February 1, 2008, in Bell County, in the Eastern District of Kentucky, and elsewhere, JOHN C. SLUSHER, aided and abetted by others, did knowingly buy, receive, possess, and obtain control of, with intent to sell and otherwise dispose of, a motor vehicle and motor vehicle parts, to wit, #74 Harley Davidson black motorcycle, knowing that the vehicle identification number (VIN) of said vehicles and parts had been unlawfully removed and obliterated, (tampered with and altered), in violation of 18 U.S.C. 2321 and 2.
COUNT 13 321 On or about February 1, 2008, in Bell County, in the Eastern District of Kentucky, and elsewhere, JOHN C. SLUSHER, aided and abetted by others, did knowingly buy, receive, possess, and obtain control of, with intent to sell and otherwise dispose of, a motor vehicle and motor vehicle parts, to wit, #75 Harley Davidson black motorcycle, knowing that the vehicle identification number (VIN) of said vehicles and parts had been unlawfully removed and obliterated, (tampered with and altered), in violation of 18 U.S.C. 2321 and 2. Kentucky, COUNT 14 18 U.S.C. 1503 On or about August 26, 2010, in Laurel County, in the Eastern District of SHON FIELDS did corruptly endeavor to influence, obstruct, and impede the due administration of justice in the Eastern District of Kentucky, to wit, by testifying falsely before a federal grand jury in London, Kentucky, while an investigation in the Eastern District of Kentucky was pending, all in violation of 18 U.S.C. 1503. Kentucky, COUNT 15 18 U.S.C. 1001 On or about May 31, 2011, in Campbell County, in the Eastern District of ROBERT W. HARRIS
did willfully and knowingly make and cause to be made materially false, fictious, and fraudulent statements and representations in a matter within the jurisdiction of an agency of the United States by falsely stating to agents with the Federal Bureau of Investigation that he had only assembled 10-12 motorcycles since January 2000 and that Matt Harris had no involvement, and that he knew the statements and representations were false because he knew then and there that he had previously certified to the Campbell County Clerk s Office, and the Kentucky Department of Transportation that he, Peggy Harris, and Matt Harris had assembled over 50 motorcycles since January 2000, all in violation of 18 U.S.C. 1001. FORFEITURE ALLEGATION 18 U.S.C. 982(a)(1) As a result of the offenses alleged in Counts 1, 2, 3, 4, 5, 6, and 7, ROBERT JASON CHAPMAN, JOHN C. SLUSHER, MARK JUSTICE, GEORGE FERGUSON, RICHARD D. MEADE, aka DICKIE, ROBERT W. HARRIS, aka TRADER BOB, SHON FIELDS, and CHRISTINA BANNIGAN shall forfeit to the United States all property, real and personal, which constitutes or is derived from proceeds traceable to violations of 18 U.S.C. 1956(h), and 1956(a)(1)(B)(i), including, but not limited to: REAL PROPERTY:
1) Real Property and buildings located at 1001 Greenup Ave., Ashland, Kentucky, in the name of Richard D. Meade, and recorded in Deed Book 527, page 271, records of the Boyd County Clerk s Office. 2) Real Property and buildings located at 1001 Winchester Ave., Ashland, Kentucky, in the name of Richard D. Meade, and recorded in Deed Book 516, page 930, records of the Boyd County Clerk s Office. 3) Real Property and residence located at 2 Twenty-first St., Newport, Kentucky and being PVA Group No. 895, and recorded in Deed Book 605, page 696, records of the Campbell County Clerk s Office. 4) Real Property and building located at 119 Kentucky Ave., Pineville, in the name of John Slusher and Shirley Slusher, and recorded in Deed Book 247, page 237, records of the Bell County Clerk s Office. CONVEYANCES: 1) Harley Davidson motorcycle, VIN #1HD1PJE144Y953890; 2) Big Dog motorcycle, VIN #5J11RBJ195W000435; 3) Harley Davidson motorcycle, VIN #1HD1BRL11VY037198; 4) Harley Davidson motorcycle, VIN #1HD1BJL4XVY013364; 5) Harley Davidson motorcycle, VIN #1HD1BJL44VY057926; 6) Thunder Mountain motorcycle, VIN #1T9C1L2686F717095. MONEY JUDGMENT $2,500,000.00 (Two Million Five Hundred Thousand Dollars), which sum represents the gross proceeds in aggregate obtained by the defendants as the result of the aforesaid violation. By virtue of the commission of the felony offenses charged in Counts 1, 2, 3, 4, 5, 6, and 7 of this Indictment, any and all interest ROBERT JASON CHAPMAN, JOHN C. SLUSHER, MARK JUSTICE,
GEORGE FERGUSON, RICHARD D. MEADE, aka DICKIE, ROBERT W. HARRIS, aka TRADER BOB, SHON FIELDS, and CHRISTINA BANNIGAN have in the above-described property is vested in the United States and hereby forfeited to the United States pursuant to 18 U.S.C. 982(a)(1). defendant, If any of the property listed above, as a result of any act or omission of the (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with, a third party; (3) has been placed beyond the jurisdiction of the Court; (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States to seek the forfeiture of any other property in which the defendant has an interest in, up to the value of the above forfeitable property, that is, $2,5,000,000.00, including, but not limited to, the following as substitute assets: REAL PROPERTY: 1) Real Property and residence located at 223 Bond Hill Rd., Barbourville, KY, in the name of JohnLefty s LLC., and of record in Deed Book 358, page 597, Knox County, Kentucky; 2) Real Property and residence located at 500 Ky Hwy 1803, Barbourville, KY, in the name of JohnLefty s LLC., and of record in Deed Book 384, page 93, Knox County, Kentucky; 3) Real Property being 150 acres on Lost Fork, in the names of John Slusher and James Golden, and recorded in Deed Book 375, page 158, Knox County, Kentucky; 4) Real Property being 51 acres on Golden Branch Rd., in the names of John Slusher and James Golden, and recorded in Deed Book 375, page 158, Knox County, Kentucky; 5) Real Property being 250 acres on Golden Branch, Middle Fork of Stinking Creek, in the name of John Slusher, and recorded in Deed Book 343, page 726, Knox County, Kentucky;
6) Real Property and building located at 107 N Main St., in the names of John Slusher and Shirley Slusher, and recorded in Deed Book 350, page 450, Knox County, Kentucky; 7) Real Property being 115 acres on Lost Fork of Stinking Creek in the name of John Slusher, and recorded in Deed Book 368, page 457, Knox County, Kentucky; 8) Real Property being 10 acres on US 25-E, Flat Lick, in the name of John Slusher, and recorded in Deed Book 313, page 538, Knox County, Kentucky; 9) Real Property and residence being 87.88 acres located at 518 Jackson Valley Rd., in the name of John Slusher, and recorded in Deed Book 245, page 128, Knox County, Kentucky; 10) Real Property and building at 251 Pine St., in the name of John Slusher, and recorded in Deed Book 327, page 693, Bell County, Kentucky; 11) Real Property and buildings at US 25E/South Pineville, in the names of John Slusher and Shirley Slusher, and recorded in Deed Book 323, page 100, Bell County, 12) Real Property at KY 2015/Fourmile, in the names of John Slusher and Shirley Slusher, and recorded in Deed Book 335, page 711, Bell County, 13) Real Property and residence at US 25E/Cannon Creek, in the name of John Slusher in an unrecorded deed, and a source of title recorded in Deed Book 241, page 602, Bell County, 14) Real Property at KY 2015/Fourmile, in the names of John Slusher, and recorded in Deed Book 275, page 140, Bell County, 15) Real Property and residence located at 123 Cedar St., Pineville, in the name of John Slusher, and recorded in Deed Book 346, page 576, Bell County, 16) Real Property and residence at US 25E/Log Mill Road, in the name of JohnLefty s LLC., and recorded in Deed Book 341, page 468, Bell County, 17) Real Property at Yoakum Lane, Middlesboro, in the names of John Slusher and Shirley Slusher, and John and Joshua Slusher, and recorded in Deed Book 335, page 711, Bell County, 18) Real Property and residence located at 521 Tennessee Ave., Pineville, in the names of John Slusher and Shirley Slusher, and recorded in Deed Book 333, page 714, PVA Map #075-20-04-017.00, Bell County, 19) Real Property and residence located at 521 Tennessee Ave., Pineville, in the names of John Slusher, and recorded in Deed Book 336, page 637, PVA Map #075-20-04-025.00, Bell County, 20) Real Property and residence located at US 25E/South Pineville, Pineville, in the name of John Slusher, and recorded in Deed Book 341, page 472, Bell County,
21) Real Property and residence located at KY 2013/Pickering Branch, Pineville, in the name of John Slusher, and recorded in Deed Book 349, page 748, Bell County, 22) Real Property and residence located at US 119/Blackmont, Pineville, in the names of John Slusher and James Golden, and recorded in Deed Book 305, page 656, Bell County, 23) Real Property and residence located at US 25E/South Pineville, Pineville, in the names of John Slusher, and recorded in Deed Book 341, page 472, Bell County, 24) Real Property at Pine St., Pineville, in the names of John Slusher and Shirley Slusher, and recorded in Deed Book 298, page 650, Bell County, 25) Real Property and building located at Oak Street, Pineville, in the name of John Slusher, and recorded in Deed Book 298, page 826, Bell County, 26) Real Property located at KY 3484/Laurel Fork, Pineville, in the name of John Slusher, and recorded in Deed Book 308, page 324, Bell County, 27) Real Property and building located at Tennessee Ave., Pineville, in the names of John Slusher and David Bush, and recorded in Deed Book 279, page 673, Bell County, 28) Real Property located at Kentucky Ave., Pineville, in the name of John Slusher, and recorded in Deed Book 338, page 361, Bell County, 29) Real Property and building located at 123 Kentucky Ave., Pineville, in the name of John Slusher, and recorded in Deed Book 300, page 265, Bell County, 30) Real Property and building located at 120 Kentucky Ave., Pineville, in the name of John Slusher, and recorded in Deed Book 339, page 190, Bell County, 31) Real Property and building located at 114 Kentucky Ave., Pineville, in the name of John Slusher, and recorded in Deed Book 333, page 295, Bell County, 32) Real Property and building located at 102 Kentucky Ave., Pineville, in the name of John Slusher, and recorded in Deed Book 323, page 546, Bell County, 33) Real Property located at Greenup Ave., Ashland, in the name of Richard Meade, and recorded in Deed Book 527, page 964, Boyd County, 34) Real Property located at 1016 Greenup Ave., Ashland, in the name of Richard Meade, and recorded in Deed Book 547, page 160, Boyd County, 35) Real Property located at 1024 Greenup Ave., Ashland, in the name of Richard Meade, and recorded in Deed Book 579, page 428, Boyd County,
36) Real Property located at Dogwood Court, Ashland, in the name of Richard Meade, and recorded in Deed Book 616, page 337, Boyd County, 37) Real Property located at Oakwood Circle, Ashland, in the name of Richard Meade, and recorded in Deed Book 616, page 337, Boyd County, 38) Real Property and residence located at 608 May Ct., Ashland, in the name of Richard Meade, and recorded in Deed Book 738, page 240, Boyd County, 39) Real Property and residence located at 1619 Bath Ave., Ashland, in the name of Richard Meade, and recorded in Deed Book 734, page 651, Boyd County, 40) Real Property and residence located at 1621 Bath Ave. and 515 17 th St, Ashland, in the name of Richard Meade, and recorded in Deed Book 672, page 662, Boyd County, 41) Real Property and building located at 259 West Central Ave. WW, in the name of Richard Meade, and recorded in Deed Book 738, page 240, Boyd County, 42) Real Property located at 706 Johnson Place WW, in the name of Richard Meade, and recorded in Deed Book 631, page 767, Boyd County, 43) Real Property and residence located at 3125 State Rt. 5, in the name of Richard Meade, and recorded in Deed Book 738, page 240, Boyd County, 44) Real Property and building located at 1017 Winchester Ave., Ashland, in the name of Richard Meade, and recorded in Deed Book 607, page 026, Boyd County, 45) Real Property located at 216 10 th St., Ashland, in the name of Richard Meade, and recorded in Deed Book 527, page 964, Boyd County, A TRUE BILL FOREPERSON KERRY B. HARVEY UNITED STATES ATTORNEY
PENALTIES COUNTS 1-7: COUNTS 8-14: COUNT 15: Not more than 20 years imprisonment, $500,000 or twice the value of the property involved in the transaction, whichever is greater, and 3 years supervised release. Not more than 10 years imprisonment, $250,000 fine, and 3 years supervised release. Not more than 5 years imprisonment, $250,000, and 3 years supervised release. FORFEITURE ALLEGATION: Forfeiture of all listed property. PLUS: PLUS: Mandatory special assessment of $100 per felony count. Restitution, if applicable.